NKF is committed to lawful and ethical behaviour in all its activities and requires that the Board of Directors, employees, volunteers and consultants conduct themselves in a manner that complies with all applicable laws, regulations and internal policies. In keeping with this commitment and NKF’s interest in promoting open communication, this Whistle Blowing policy (“the Policy”) aims to provide a means through which employees and members of the public could, in good faith, raise concerns with the assurance that they will be protected from reprisals or victimization.
The Policy is intended to cover serious concerns that could have a significant impact on NKF, including those that:
- may lead to incorrect financial reporting;
- are unlawful;
- are not in line with NKF code of ethics; or
- would otherwise amount to serious improper or unethical conduct.
Harassment or Victimization
No employee or general member of the public who in good faith reports a violation of the Policy shall suffer harassment, retaliation or adverse employment consequence.
Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
The Policy encourages employees and general members of the public to put their names to complaints in order to facilitate appropriate follow-up and investigation. Complaints lodged anonymously would, subject to the Policy, be investigated. Consideration will be given to:
- seriousness of the issue(s) raised;
- credibility of the concern(s) and
- likely availability of confirmation for the complaint(s) from attributable source(s).
Malicious allegations by NKF staff will result in appropriate disciplinary action being taken.
PROCEDURE FOR REPORTING
The procedure should only be used for reporting serious and sensitive issues. Serious concerns relating to incorrect financial reporting, unlawful activities, behaviour that is not in line with NKF’s code of ethics or any activity that amounts to a serious improper or ethical conduct should be reported to the following:
The policy encourages the whistleblower to leave behind their name, email address and contact number within the email or telephone call to facilitate appropriate follow-up and/ or investigation.
The earlier a concern is expressed, the easier it is to take action to address such concern. To ensure the factual accuracy of all complaints so that measures could be taken to mitigate or remedy them, all complaints should be lodged as soon as practicable.
Although the complainant is not expected to prove the truth of an allegation, the complainant needs to demonstrate that he or she has a reasonable basis for the concern.
HANDLING OF COMPLAINTS
The actions to be taken will depend on the nature of the complaint(s). The Board Chairman and the Audit & Risk Committee (ARC) Chairman shall determine, in the advice of the ARC members, whether an investigation is appropriate and the way forward. Some concerns may be resolved through an agreed course of action without the need for investigation. Should an investigation be decided upon, the Board Chairman and the ARC Chairman shall jointly decide to consult other Board members in making this decision, if necessary.
In the event a decision was made to proceed with an investigation, the Internal Auditor appointed by NKF and empowered to investigate shall proceed with the investigation, unless the Board Chairman and the ARC Chairman jointly decide that another committee or party be tasked to oversee the investigation. The committee or party overseeing the investigation shall ensure that it receives a report on each complaint and a follow-up report on actions taken to address it. The Board Chairman and the ARC Chairman should be kept informed of the progress of any investigation and approve any action to be taken upon completion of the investigation at the advice of the ARC members.
Report to Complainant
If the complainant has identified himself or herself, he or she will be given a status report on his or her complaint within four weeks after the complaint was initially made and such report shall include:
- an acknowledgement of the complaint;
- an indication on how the matter will be dealt with;
- related information to the complainant whether initial inquiries have been made;
- related information to the complainant whether further investigation will be undertaken and, if not, the reasons for that decision; and
- an estimated turn-around time for a final response should further investigation(s) be undertaken.
The amount of contact between the complainant and the body investigating the complaint will depend on the nature of the issue and the clarity of the information initially provided. Further information may be sought from the complainant in order to facilitate investigation and to ensure that all pertinent factors are taken into account in the investigation.
Subject to legal constraints, the complainant will receive appropriate report about the outcome of any investigations.